Direct Debits: Shadow Shopping Exercise

A review into the operation of clause 20.1 of the Mutual Banking

Code of Practice

March 2011

2

About the Code Compliance Committee (CCC)

In July 2009, Abacus Australian Mutuals (“Abacus”), the official industry body

for the Australian mutual financial services sector launched the Mutual

Banking Code of Practice (“the Code”). This voluntary Code is designed to

establish and improve service delivery and business practices for those credit

unions and mutual building societies that subscribe to it (“Mutuals”).

The Code also created an independent code monitoring body, the Code

Compliance Committee (“the CCC”). The CCC commenced its role in

October 2009, ensuring that Mutuals meet the standards of good practice

they agreed to adopt.

The CCC has appointed the Financial Ombudsman Service (“FOS”) as its

compliance manager to assist it in overseeing compliance with the Code

through the implementation of a code compliance program.

This compliance program has three core activities: monitoring, investigating,

and influencing.

Alongside the key functions of monitoring and investigating the CCC’s

influencing role involves undertaking research into a particular requirement or

requirements of the Code and reporting on those findings to influence and

encourage positive changes in industry practices and promote industry

improvements.

This Report describes the results of a recent review of Direct Debits obligations

under the Code and provides a number of initial recommendations.

3

Contents Executive Summary ........................................................................................................................... 4

Purpose and Scope .......................................................................................................................... 5

Overview .............................................................................................................................................. 6

Our Findings ......................................................................................................................................... 8

The Results ...................................................................................................................................... 10

Observations ..................................................................................................................................... 11

Examples of Responses from Mutuals’ Customer Service Representatives .................... 12

Conclusion ......................................................................................................................................... 15

Annexure A ........................................................................................................................................ 16

Sample Script for shadow shopping ...................................................................................... 16

Some useful tips on conducting the shadow shopping exercise .................................. 16

Extracts from the Mutual Banking Code of Practice ......................................................... 18

Summary of relevant sections of the BECS procedures ................................................... 18

Annexure B......................................................................................................................................... 19

Additional observations ............................................................................................................. 19

Extracts from the Mutual Banking Code of Practice ......................................................... 19

Summary of relevant sections of the BECS procedures ................................................... 20

Contacting the CCC ...................................................................................................................... 21

4

Executive Summary

Direct debits are a popular and convenient method of managing payments used

by consumers and businesses. The volume of transactions has grown steadily over

the past 5 years1, and in 2010, the average number of direct debit transactions was

2.3 million per business day with an average value per business day totalling $19.3

billion (AUD)2.

Under Clause 20.1 of the Code, Mutuals agree to promptly stop a direct debit facility

linked to a member’s transaction account (as opposed to a credit card) whenever

the member asks the Mutual to do so. The ability to cancel a direct debit is a

powerful right that allows members to retain control over their accounts. Referring a

member to the debiting merchant or service provider instead would not comply

with the Code.

Both the Financial Ombudsman Service (FOS)3 and Abacus4 have previously taken

steps to highlight these obligations to Mutuals and in August and November 2010 the

CCC conducted a shadow shopping review to assess the level at which Mutuals

were complying with Clause 20.1 of the Code.

The August 2010 review found that, an average of 7 out of 10 of Mutuals surveyed

provided incorrect or inadequate advice at their call centre level on this issue. The

CCC shared these findings with Mutuals and key stakeholders. In November 2010 the

CCC retested the original sample of Mutuals and found a ten percent (10%)

improvement in Mutuals’ practices (with 4 out of 10 being fully compliant). This

improvement level did not meet the CCC’s expectations.

Based on these findings the CCC recommends that all Mutuals ensure that all their

staff are adequately trained and understand the obligations under the Code and

1 Australian Payments Clearing Association (APCA) Annual Review 2009, p. 23, retrieved on 10 August,

2010 from http://www.apca.com.au/AR2009/pdf/apca_2009_annual_review.pdf 2 APCA Annual Review 2010, p. 33, retrieved on 11 January, 2011 from

http://www.apca.com.au/AR2010/apca_ar2010.pdf 3 Financial Ombudsman Service, Banking and Finance: Bulletin 60, pp. 5-6, retrieved on 20 August, 2010,

from http://www.fos.org.au/centric/home_page/publications/bulletins/banking_finance_bulletins.jsp 4 APCA The Ins and Outs of Direct Debit retrieved on 20 August, 2010 from

http://www.apca.com.au/Public/apca01_live.nsf/ResourceLookup/Direct_Debit_Brochure_2009.pdf/$Fi

le/Direct_Debit_Brochure_2009.pdf

5

the Bulk Electronic Clearing System5 (“BECS”) rules developed by the Australian

Payments Clearing Association’s (“APCA”).

A copy of the CCC’s report will be published on its website and shared with key

stakeholders, including all Code subscribers, Abacus Australian Mutuals, the chair of

the Mutual Banking Code Compliance Committee Association (MBCCCA), the

Australian Payments Clearing Association (APCA) and the Australian Securities and

Investments Commission (ASIC) . We have also prepared a sample shadow

shopping script to assist Mutuals in conducting their own compliance reviews (see

Annexure A).

Purpose and Scope

The purpose of this review was

to ascertain the extent to which Mutuals complied with Clause 20.1 of the

Code, and

to gather the range of responses provided to the shadow shopper and test

the shadow shopper’s experience against the requirements set by the Code.

The scope

Code subscribing mutuals (“Mutuals”)6;

Direct Debit Requests (DDR)

Requests to process a direct debit cancellation

Transaction accounts, and

Mutuals’ call centres7

Considered outside of scope

Processing of complaints about unauthorized or irregular direct debits

Credit Card accounts

Debit Card transactions8, and

Compliance assessment against the Bulk Electronic Clearing System (BECS)

rules.

5 APCA members are required to comply with the APCA BECS Rules –for further details see Annexure A

to this report. 6 A list of Mutuals can be found at http://www.cccmutuals.org.au/code-subscribers/ 7 Each Mutual that was “shadow shopped” has been provided with a copy of this report and notified

individually with their results in the review. 8 Debit cards using the scheme account number (i.e. Visa or MasterCard card number) are not

covered by the direct debits requirements of the Code. However, debit cards are covered if the

underlying account number and BSB are provided to facilitate the direct debit request.

6

Overview

According to APCA 2010 Annual Report, the average direct debit transaction

volume has grown steadily from 1.7 million per day in 2005 to 2.3 million per day in

20109 with an average value of processed direct debits per business day of $19.3

billion (AUD) in 201010.

Source: APCA Annual Review 201011

9 APCA Annual Review 2010, p. 33, retrieved on 11 January, 2011 from

http://www.apca.com.au/AR2010/apca_ar2010.pdf 10 APCA Annual Review 2010, p. 33. 11 APCA Annual Review 2010, p. 33.

Direct debit

Direct debit is a simple and convenient way for consumers to make regular

payments straight out of their financial institution account. It is most often

used for regular transactions like mortgage repayments, insurance premiums

and utility bills. To pay by direct debit, consumers need to complete a Direct

Debit Request (DDR) authority with the business or company (the biller) that

they wish to pay. The DDR gives the biller permission to collect payments

from the consumer’s account on a regular agreed date without the

consumer having to manually arrange a payment. Once the biller has

initiated the collection process payment is made through the financial

institution where the consumer’s account is held.

Billers that accept DDRs from consumers are known as Debit Users. There are

some 18,000 Debit Users in Australia.

(APCA Annual Report 2009)

7

Given the significant volumes and values associated with direct debit transactions,

the CCC and APCA consider the Code’s application to those transactions to be an

important aspect of the overall applicable consumer protection framework12.

In that regard:

under Clause 20.1 of the Code, the Mutuals are required to stop a direct debit

facility linked to a member’s transaction account promptly upon request by that

member

while it may be considered good practice and common courtesy for a Mutual’s

member to notify the debiting business or merchant of the change in the

payment method, Mutuals should not be directing or suggesting to their

members that they should first raise the request directly with the business or

merchant, and

the ability to stop or cancel a direct debit request (DDR) via a Mutual is a

powerful safeguard for members, especially for those in financial difficulty. In part

it allows them to end a commercial arrangement independently, away from

potential confrontation or sales pressures from the merchant or service provider.

In addition, such members may be placed in further difficulty if a Mutual was to

reject or fail to act on a request to stop a direct debit and/or where exception

and penalty fees are subsequently imposed on the account.

12 Code Compliance Monitoring Committee, Direct Debits report, p. 16, retrieved on 10 August, 2010

from http://www.codecompliance.org/uploader/ccmc_retrievefile.aspx?pid=15

8

Our Findings

The CCC conducted two shadow shopping exercises (in August and November

2010) across selected subscribing Mutuals to determine the extent to which Mutuals’

staff members were complying with Clause 20.1 and correctly advising customers on

how to cancel a direct debit arrangement.

In each exercise, 43 calls were made across 33 call centres. Ten (10) of these call

centres were Mutuals named in KPMG’s 2009 report “Top 15 largest building

societies and credit unions”13 – the CCC shadow shopped these call centres twice.

The locations of the selected Mutuals were as follow:

ACT NSW NT QLD SA TAS VIC WA TOTAL

1 12 1 5 3 1 8 2 33

The shadow shopping process involved a telephone contact to the selected call

centres or relevant branches with a general enquiry regarding the cancellation of a

direct debit request. This review also gathered additional information in relation to:

fees

the time period for the DDR cancellation to take effect, and

general observations regarding service standards.

13 KPMG, Building Societies and Credit Unions: 2009, p. 2, retrieved on 2 August, 2010 from

http://www.apca.com.au/AR2009/pdf/apca_2009_annual_review.pdf

Total of 43

contacts to call

centres

Two calls each to

10 Mutuals listed in

the KPMG report

23 calls to

randomly

selected Mutuals

9

The CCC used a template enquiry script (based on a fictional mobile telephone

contract with a direct debit facility) to ensure a consistent, comparable and robust

approach (see Annexure A).

The compliance assessment was based on a review of the responses provided by

call centre staff which were classified into three possible outcomes:

Compliant – Mutual meets the requirements of the Code

Non-Compliant (Partial) – Mutual staff recommended that the cancellation

should be lodged with the merchant first and if there was a problem the

member could return to the Mutual to cancel the direct debit, and

Non-Compliant (Full) – Mutual staff did not accept the cancellation request

and advised that the cancellation could only be lodged with the service

provider or merchant.

The key determinant was whether the shadow shopper was directed by the Mutual

to initially refer their request for the cancellation of the direct debit to their service

provider or merchant – which is in contravention of Clause 20.1 of the Code:

Example of responses provided Compliance with Clause 20.1

Yes, you can cancel the direct debit facility with us;

however, you should also contact your mobile

service provider.

Fully compliant (F)

No, you should go to your mobile service provider

first and only if you have difficulties there, you can

contact us to cancel your direct debit facility with

us.

Partially compliant (P)

No, you have to go to your mobile service provider

to cancel your direct debit.

Non-compliant (N)

Overall, the November 2010 exercise identified that despite the August review

Mutuals still failed to achieve compliant outcomes in 6 out of 10 of our shadow

shopper contacts14.

14 The total number of responses that were either non-compliant (full) or non-complaint (partial) was 26

out of a total sample size of 43.

10

The Results

The August 2010 report (using the same processes as in this, November 2010, review –

and subsequently shared with the Mutuals) had found that that 7 out of 10 Mutuals

surveyed had provided incorrect or inadequate advice in relation to the

cancellation of a direct debit request.

While the November 2010 follow up review found a ten percent (10%) improvement

in Mutuals’ practices (with 4 out of 10 being fully compliant) this level of change fell

short of the CCC’s expectations.

The analysis of the ten call centres that were included in KPMG’s 2009 “Top 15

largest” report and the other randomly selected Mutuals identified that:

Fully compliantPartially

compliantNon-compliant

Aug-10 30% 28% 42%

Nov-10 40% 30% 30%

0%

10%

20%

30%

40%

50%

Co

mp

lian

ce (

%)

Total Compliance with Clause 20.1

Fully Compliant

Partially Compliant

Non-compliant

Aug-10 25% 40% 35%

Nov-10 35% 30% 35%

0%

10%

20%

30%

40%

50%

Co

mp

lian

ce (

%)

Compliance with Clause 20.1 for the "Top 15 largest"Across 20 contacts made

to Mutuals rated in the

“Top 15 largest”, only 5

contacts (25%) were fully

compliant in the August

2010 review.

In the November 2010

review, the CCC found a

10% improvement in

these Mutuals’ practices

(up to 35% fully

compliant).

11

The analysis of the other randomly selected Mutuals identified that:

Observations

The ability to cancel direct debits varied across the Mutuals surveyed. Some

Mutuals allowed members to cancel:

- on the phone as long as they were registered for telephone banking

- by fax

- by e-mail, or

- at branch networks.

The majority of Mutuals sampled required members to put the request in

writing for the cancellation to take effect. In some cases a letter or form could

be faxed or emailed as an attachment. Alternatively, the member could

attend a branch to lodge the request.

Cancellation via internet banking was not available.

All Mutuals that advised they could cancel a DDR said the cancellation

would take effect within 24 hours of the member requesting the cancellation.

Two Mutuals charged a fee for processing a cancellation or stop. One Mutual

charged a $12.50 “cancellation fee” and the other charged a fee of $15.38

for each stop request.

Overall, even though some customer service representatives (CSRs) gave

incorrect information, they were very friendly and professional and the

majority of calls were answered within one minute.

Fully Compliant

Partially Compliant

Non-compliant

Aug-10 35% 17% 48%

Nov-10 43% 30% 26%

0%

10%

20%

30%

40%

50%

Co

mp

lian

ce (

%)

Compliance with Clause 20.1 for "Other Mutuals"In the August 2010

review, 35% of the

randomly selected

Mutuals reviewed were

fully compliant across the

23 contacts made.

In the November 2010

review the CCC found

that 43% of the Mutuals’

reviewed were fully

compliant.

12

Examples of Responses from Mutuals’ Customer Service

Representatives

Fully Compliant

CSR advised that the DDR could be cancelled directly with the Mutual,

however it was best to also advise the phone provider that the DDR had

been cancelled to avoid the fees charged on phone accounts for a rejected

DDR.

CSR was happy to cancel DDR immediately and requested the telephone

banking password to proceed with the DDR cancellation. CSR advised that

there was no fee to cancel the DDR with the Mutual and said that the

cancellation would be effective in 24 hours.

CSR advised that in order to cancel the DDR, the shadow shopper would

need to visit a branch to complete a cancellation request form. CSR further

advised that the shadow shopper bring in a copy of the telephone bill and

contact details for the phone company so that the branch staff could

contact the phone company and advise that the DDR on the account had

been cancelled for future direct debits.

CSR advised that to cancel the DDR, the shadow shopper needed to put the

request in writing as a signature was required for the cancellation to take

effect. The request could be faxed or emailed as an attachment and the CSR

provided the relevant fax number and email address. The CSR also suggested

that the shadow shopper should contact the phone company to inform them

that a DDR was no longer applicable and to arrange for an alternative

payment method.

13

Partially Compliant

CSR advised that as the shadow shopper had set up and authorised the

phone company to take payments from the account monthly, the shadow

shopper would need to speak to the provider to cancel the DDR. However, if

that was unsuccessful in cancelling the DDR, the shadow shopper could

contact the Mutual and it would then cancel the DDR.

CSR said that the shadow shopper would need to contact the phone

company first to cancel the DDR as the DDR was set up by the phone

company. CSR added that if the phone company still continued to debit

account, the shadow shopper could then write to the Mutual to request it to

stop the direct debit on the account. The CSR provided details on what to

include in the letter.

CSR advised the shadow shopper that the first point of contact would be the

phone company as the DDR was set up by the phone company. The CSR

said that if the shadow shopper had no luck with cancelling it with the phone

company, the shadow shopper could request the Mutual to cancel the DDR.

However, the shadow shopper would need to show proof that they had tried

to cancel the DDR with the phone company (i.e. provide the Mutual with a

copy of the letter to the phone company requesting the DDR cancellation)

and that they had been unsuccessful.

CSR was unsure about the process for cancellation. The CSR initially advised

that the Mutual could cancel the DDR and said that chances were that the

phone company would still try to debit the account. However, when the

shadow shopper asked for further details on how to cancel, the CSR changed

the advice and directed the shadow shopper to the phone company to

cancel the DDR.

14

Non-compliant

CSR advised that only the phone company could cancel the DDR as the

shadow shopper had authorised the phone company to debit the account

and it was set up by the phone company. The CSR added that the Mutual

acts as a “middle man” and only the phone company could cancel the

arrangement.

CSR said that as the DDR was initiated by the phone company, only the

phone company had the authority to cancel it. The CSR advised that if the

payment had been arranged by the Mutual, then the Mutual could cancel it.

CSR added that, for future reference, it was best to organise any DDR

arrangements directly with the Mutual as it was easier to make changes to

the account.

CSR directed the shadow shopper to the phone company to cancel the

DDR. The CSR said that only the phone company could cancel the DDR and

the arrangement had nothing to do with the Mutual. The CSR also advised

that once the shadow shopper had cancelled the DDR with the phone

company, the shadow shopper should also contact the Mutual to put a stop

on the account as a precaution.

CSR said that the shadow shopper had to speak to the phone company as

the shopper had entered into an agreement with the phone company and

would therefore need to sort it out with the provider. The CSR said that it was

not the responsibility of the Mutual as the shopper had changed their mind

and did not want the phone company to debit the account. The CSR did

mention putting a permanent stop on the account but when asked for further

details said that it would be best for the shopper to discuss it with the phone

company.

15

Conclusion

The aim of this review was to effect positive compliance improvements so that

members of Mutuals are able to cancel direct debits in accordance with Clause

20.1 of the Code.

In order to address the issues identified in the review, the CCC will provide an

electronic copy of this report to all Mutuals and provide them with an opportunity to

discuss the findings. The CCC will also refer the Mutuals to APCA’s resources on DDRs

and remind the Mutuals about their commitments under the Code.

In addition, the following is a list of further recommendations that Mutuals may wish

to consider to improve their compliance in this area:

ensuring appropriate information is available for staff to understand the

Mutual’s key obligations and processes required to stop a direct debit facility

linked to a transaction account, and

increasing staff awareness regarding the impact of incorrect advice,

particularly upon members experiencing financial hardship.

16

Annexure A

Sample Script for shadow shopping

SAMPLE QUESTIONS

1. “I have a monthly direct debit of $49 with a mobile phone company that

comes out of my [include nominated account description]. I gave my phone

company my BSB and account number when I initially signed up. I am

thinking about stopping the direct debit. How can I do it?”

2. “Can I just tell you to cancel it, or do I have to contact my mobile phone

company?”

3. “Can I cancel the direct debit by telephone or the internet - or do I have to

complete a form or come to your office/branch?”

4. “Is there a fee? If so how much is it?”

5. “How long before the cancellation takes effect?”

Some useful tips on conducting the shadow shopping exercise

The scenario should relate to a request for information on how to stop a direct

debit linked to a transaction account.

Select a suitable business or merchant for the scenario. For example, the CCC

used a scenario where the shadow shopper/“member” stated they had

established a direct debit by completing an authority form with an unnamed

mobile phone company as part of the phone contract sign up process.

Ensure that the account in question is a normal Mutual transaction account, not

a credit card (as the obligation under the Code only applies to transaction

accounts). Where a credit card is involved a member must inform the merchant

or service provider of the cancellation, in this case the mobile phone company.

To achieve a compliant outcome, the Mutual’s staff need to advise the shadow

shopper/“member” that after proper identification of the member, the direct

debit will be stopped by the Mutual.

In constructing the dialogue with the Mutual, the shadow shopper/ “member”

should also anticipate what other additional information a real member might

request and incorporate this into the shadow shopping conversation.

17

For example:

1. the different ways how a direct debit can be stopped

2. any fee (if applicable) for the stop, and

3. how long it takes for the stop to take effect.

If the Mutual’s staff ask for account details, the shadow shopper/“member”

should politely decline saying that at this stage they only want some basic

information on the cancellation process.

The shadow shopper’s/“member’s” request should be focused on a permanent

stop or cancellation of the direct debit. Accordingly, the shadow

shopper/“member” should note if the Mutuals is only offering a temporary stop

instead of a cancellation. If only a temporary stop is offered, the shadow

shopper/“member” should seek further information e.g. the duration of the stop

and how to permanently stop the direct debit.

In some cases, the Mutual’s staff may direct the shadow shopper/“member” to

first raise the request directly with the merchant/service provider before providing

any further assistance on behalf of the Mutual. The Mutual’s staff may also

suggest that if the request to the merchant or service provider is unsuccessful, the

shadow shopper/“member” should then contact the Mutual again to stop the

direct debit. The shadow shopper/“member” should note when this occurs as this

is only partially Code compliant.

The shadow shopper/“member” should seek further information about how the

direct debit can be stopped, e.g. by telephone, in writing (either using a form or

by letter), over the internet or at a branch. The Mutual may also request that the

shadow shopper/“member” also contact the mobile phone company to advise

them of the change in the payment method.

The shadow shopper/ “member” should record all of the questions that were

asked and try to keep the conversation flowing naturally using the answers

provided by the Mutual.

18

Extracts from the Mutual Banking Code of Practice

Clause 20: Stopping direct debit and recurring payment arrangements

20.1 We will promptly stop a direct debit facility linked to your transaction account

with us whenever you ask us to do so.

Summary of relevant sections of the BECS procedures

Cancellation of direct debits

Clause 7.12(h) of the BECS procedures requires a customer’s bank (Ledger FI) to:

1. Accept an instruction in writing, or in any such form as it determines, from a

customer to cancel a direct debit;

2. Act on that instruction by promptly forwarding a cancellation request to the

debit user’s bank (Sponsor); and

3. Ensure, as far as practicable, that no further debits under the relevant debit

authority are posted to the customer’s account.

19

Annexure B

Additional observations

The following is a list of further recommendations that Mutuals may wish to consider

to improve their compliance with Clauses 20.2 and 20.3 of the Code:

improving the information and resources available to both staff and members

to provide a clear understanding of how members can dispute a transaction

and recover unauthorised direct debits, and

immediately communicating to staff members and providing additional

training if required to address any knowledge and skill gaps in call centres

and branch networks regarding stopping direct debits.

Extracts from the Mutual Banking Code of Practice

Clause 20: Stopping direct debit and recurring payment arrangements

20.2 We will accept and process your complaint that a direct debit facility was not

authorised or is otherwise irregular. However, we may request that you

endeavour to resolve the complaint with the merchant or supplier first.

20.3 Where possible, we will assist you to seek a chargeback of any unauthorised

payments debited to your scheme credit or debit card account (e.g.

MasterCard, AMEX or VISA card) pursuant to a recurring payment

arrangement. The situation may occur, for instance, where payments

continue to be debited to your account even though you have cancelled

the recurring payment arrangement (also see Clause 21: Seeking a

Chargeback on your behalf).

20

Summary of relevant sections of the BECS procedures

Unauthorised or irregular direct debits

Clause 7.8 sets out the claim procedures for Ledger FIs and Sponsors to follow when

a complaint is received from their customer that a direct debit is unauthorised or

irregular:

1. When a customer approaches the Ledger FI, the bank must, after determining

that the claim appears valid, obtain a customer claim form from the customer;

2. The Ledger FI must then forward the claim and claim request to the debit user’s

Sponsor, demanding payment;

3. The Sponsor must forward the claim to the debit user and require the debit user

to provide evidence to support its authority to effect the direct debit;

4. The Sponsor must then respond to the Ledger FI in respect of the claim:

a) in the case of disputed debits no older than 12 months, within 5 business

days; and

b) in the case of all other disputed debits, within one month.

5. The Ledger FI must inform the customer of the Sponsor’s response within one

business day of the expiry of the period for the Sponsor’s response;

6. If the Sponsor accepts the claim, or fails to respond within the specified time, the

Ledger FI may refund the customer and draw on the Sponsor’s claims account;

7. If the Sponsor refuses the claim, for example because the debit user claims it was

authorised, and the customer still wishes to dispute the debit, the Ledger FI will

again write to the Sponsor;

8. The Sponsor and Ledger FI must “use reasonable endeavours to resolve the

dispute”; and

9. There is an option for an unresolved matter to be referred to a Management

Committee constituted under the BECS regulations.

21

Contacting the CCC

If you have a complaint

If you believe that a Mutual has breached the Mutual Banking Code of Practice,

and they have subscribed to the Code, then you can:

1. Telephone CCC General Enquiries on 1300 780 808 *

2. Write to the CCC, care of:

Executive Manager

Code Compliance Committee

PO Box 14240

Melbourne VIC 8001

3. Lodge a complaint via our online complaint form at

www.cccmutuals.org.au

If you have a general enquiry

You can contact us directly using the postal address and telephone details above.

You can also email your enquiry to us at ccc@fos.org.au *

If you want to pass on some feedback

You can call us on 1300 780 808* between 9am and 5pm (Melbourne time) or use

our email address ccc@fos.org.au *

If you want to know more about the Mutual Banking Code of Practice

If you would like to know more about the Code, you can see it on our website or

alternatively have a look at the Abacus Australian Mutuals website at

www.abacus.org.au

If you have a media enquiry

Any media inquiries regarding the Committee's work should be referred to the

Executive Manager, Damian Paull, at dpaull@fos.org.au *,or by telephone on 1300

780 808*.

General information about our work is available via our website

www.cccmutuals.org.au.

*CCC has appointed the Financial Ombudsman Service (FOS) as its compliance manager to carry out

its day to day functions, including initial receipt of telephone calls, emails etc.